September 07, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590-0001

Summary:

Request for exemption from provisions to allow the use of small unmanned aerial systems on 

land controlled by self for aerial photography and videography, event photography and 

videography and real estate photography and videography

I, JohnPaul Cloutier, respectfully request an exemption from several provisions of Title 14 of the 

Code of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial system 

(sUAS) for the use of aerial photography and videography, event photography and videography,

and real estate photography and videography.

Contact Information

If there are any further questions regarding this request for exemption, please contact me using 

the contact information below:

Name: JohnPaul Cloutier

Mailing Address: 6 Mallory Court

Bristol, RI 02809

Phone: 401.465.6682

email: jpcloutier16@gmail.com

The Extent of relief you seek and the reason you seek the relief;

Section 333 prohibits the use of Unmanned aircraft system (UAS) for commercial purposes on 

private property. I am seeking an exemption to provide a commercial service to real estate 

professionals, private landowners, private event coordinators and companies who wish to obtain 

and capture Aerial photo and videos of said property for purposes including real estate listings, 

insurance property claims, and for the use as a marketing tool for businesses as well aerial 

photography and video of special events.

How your request would benefit the public as a whole;

I am seeking this exemption to serve the public as a whole by providing an opportunity for small 

business owners, real estate professionals and others who may wish to benefit from aerial 

photography and videography for marketing or personal use. 

The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek the exemption;
I have read, therefore understand the importance of different uses and safety concerns 

regarding FAA regulated airspace, and would not put air safety in any risk. When flying for this 

commercial purposes I would be flying at a maximum height allowed by the FAA. As the Pilot In 

Command (PIC), I would at all times keep visual contact between myself and the UAS knowing 

the location at all times. I would also be able to scan the airspace at which it is operating to see 

and avoid all other air traffic or objects aloft or on the ground. UAS will only be operated in safe 

environments that are strictly controlled and away from disaster areas, sporting events, high 

pedestrian or vehicle areas putting any person or persons in any risk of injury. UAS, at all times, 

will be flown within the guidelines of manufactures recommendations. Preflight inspections of 

UAS will always be performed to ensure that UAS is found to have no defects.

If you want to exercise the privileges of your exemption outside the United States, you 

must state the reason;

I have no intention on using this exemption outside the United States.

The Specific section or sections of 14 (C.F.R.) from which you seek an exemption;

I believe an exemption from the following provisions to conduct the operations mentioned in this 

request are required. To the extent that the FAA believes that additional relief is required to 

conduct the operations described here, we request an exemption from such regulatory provision 

as well.

14 C.F.R. §91.119 Minimum safe altitudes: General

The only relief from this section is from the minimum altitudes listed in paragraph 

c. Relief is required is for fixed wing operations because operations conducted at 

500 feet or higher is found to inappropriate for the current use of the UAS. Since 

operations at this altitude also pose a heightened risk of collision safety can only 

be assured through the grant of an exemption. 

14 C.F.R. §91.121 Altimeter settings

As the UAS may not have a barometric altimeter, but instead a GPS altitude read 

out, an exemption may be needed. An equivalent level of safety will be achieved 

by the operation (PIC), pursuant to the user manual and Safety checklist, 

confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight.

14 C.F.R. §91.151 Fuel requirements for flight in VFR conditions

Operating the UAS in a pre-defined area with less than 30 minutes of reserve 

fuel does not raise the type of risk outlined in §91.151. I do not intend to use the 

UAS for point-to-point flights and will not operate the UAS beyond visual line of 

sight, nor will the UAS require an airport in order to land. I believe that a 25% 

battery reserve is more than sufficient to meet this objective.

14 C.F.R. §91.405, §91.407, §91.409 Maintenance and Inspections

I believe an exemption from these requirements is appropriate since there are no 

known maintenance and inspections standards for UAS at this time.

14 C.F.R. §
Any additional information, views or arguments available to support your request;

I, as Pilot in Command, have flown numerous flight in remote areas as a hobbyist simulating 

flight for future commercial use to gain familiarization with the characteristics of his UAS 

performance under different temperature and weather conditions. As a safety precaution, I will 

perform a preflight inspection of the UAS before each flight as outlined in the User Manual. My 

intent is to only fly in non-populated, residential or rural areas and stay clear of all utility lines, 

and other dangerous obstacles. I intend to be fully aware of my surroundings at all times and to 

fly the unmanned UAS within visual line of sight and only in visual flight conditions.

I intent to follow all suggested safety regulations as listed, but not limited to below;

● Intelligent flight battery safety guidelines will also be followed.

● Phantom 3 Safety Guidelines 

● Pre-flight checklist will be performed according to Manufacturer's guideline.

● Always keep UAS in sight and under control.

● All flight limites and No-Fly Zones will be floowed.

● Owner's manual flight environment requirement will be followed at all times.

● Keep children out of the vicinity of the UAS.

● UAS will be kept clean and carrefour when not in use.

● Batteries will be removed when not in use.

● UAS will never be operated 

I understand and will comply with all health and safety regulations for PICs and will be the only 

operator under this exemption.

Attachments;

● Phantom 3 Safety Guidelines Disclaimer

● Intelligent Flight Battery Safety Guidelines

● Phantom 3 User Manual

Unmanned Aircraft System (UAS) of use;

Phantom 3 is DJI quadcopter and is capable of capturing 1080p video and captures 12 

megapixel photos.. The UAS uses GPS signalling, and when unavailable Vision 

Positioning System will allow the UAS to hover accurately in place.

Weight: (Battery & Propellers): 1,280g (2.82 lbs)

Diagonal Size (including Propellers): (23 inches)

Maximum Speed: (35 mph)

GPS Mode: GPS/GLONASS

Operating Frequency: 2.400 GHz-2.483GHz

Battery: 6000 mAh LiPo 2S

Working Voltage: 1.2 A @ 7.4V

Transmitter Power (EIRP): FCC: 20dbm; CE: 16 dbm

This device complies with part 15 of the FCC Rules and FCC radiation exposure limits.
Respectfully submitted,

JohnPaul Cloutier